My EIA Principles

 

My EIA Principles 


No.1 - Don't Fear It


Environmental Impact Assessment is not something someone is making you “do” to your project. Okay, it might be that. But I encourage you to change your mindset if you think it is. Make EIA itself a part and parcel of making your project something great, and you will reap the rewards.

The first thing I’d say, then, is allow for it. Be ready for the true cost and time that might be needed, right from the off. You don’t know for certain it’s required, sure, but either you’ve covered your liabilities or you have more liquidity and time before submission than you thought. Neither is a bad outcome.


Ask the hard questions now. Informally with your experts, or formally through the EIA screening process. You might think you don’t want to know the answers but I promise you do. We can deal with just about anything once we know, but until then the building blocks of getting your project ready to submit won't be in place. At least, not in the right place.


There’s a tendency when planning projects, rightly, to want to be ready for the worst when it comes to all manner of variables, but that doesn't always seem to apply to EIA. Maybe some genuinely don't know what it is. But for some deep down perhaps we don't want the EIA answer because we don’t fully understand it, we know it’s regulated in law, we think we can't control it, we see it only as more cost and time, and we fear what it might mean for our project. So our natural optimism for - and belief in - our project lets us imagine it’s not needed and hope for the best, or worse hide our faces and hope no one notices.


In my experience the most costly and time-consuming EIA is the one that wasn’t planned for, that the client didn’t see coming, didn’t know about or didn’t want to face, didn’t ask early enough. By then our opportunities to minimise negative effects and enhance positive ones through design may be vastly reduced, the otherwise meticulously planned project programme and budget is thrown, everything becomes a rush, and complexity and costs inevitably go up.


With time you have options. And with options you have some control. The sooner you know if EIA is in the project plan the better you can prepare, and the more efficiently you can do what’s needed.


So to my second key message. Don’t panic if your project is screened as requiring EIA. Breathe. Think. You allowed for it (clever you, see above) and now with any uncertainty gone, the opportunity is in front of you to embrace what EIA can do for your project. Make it better, help you achieve the consent you need to move forward, and in some instances even reduce the cost of the project overall through planned rather than reactive (or even...dare I say...emergency) mitigation and monitoring.


I have, very recently, managed two projects that could genuinely have gone either way at EIA screening. Both required EIA as it turned out, and since the uncertainty about significance of environmental effects was genuine that’s entirely right and proper - the precautionary principle. We moved quickly to scoping, engaged proactively and with foresight, and we agreed a very limited scope (in one example covering only three technical topics). Then we carried it out efficiently, and our contribution to achieving planning permission was done.

Think of it this way. It’s not in my - or any EIA consultant’s - longer term interests to make it any more complicated or expensive than it needs to be. No one will ever ask me to help them if I do.


I really do believe it serves us all - developers to local authorities, architects to engineers and consultants - to do EIA well when it’s justified and necessary and it serves a clear purpose, and to avoid doing it unnecessarily when it’s not. That's what the Regulations intended. I will always work hard - and push our project teams to help me - to make the case for EIA not being required if the position is justifiable.


But I also won’t apologise for EIA when it’s needed.


There is a reason EIA exists - to provide information to inform a consent decision, to protect the environment and humans from the negative effects of inappropriate development, to enhance and maximise the positive benefits of good development, and to lead ultimately to better, more considered and well-designed projects.


That’s not something to apologise for.


First published on LinkedIn, May 2020


Andy Mitchell 

BA Hons MSc MRTPI CEnv FIEMA